Who counts as the importer of record
The importer is the US owner or buyer of the honey at the time it's offered for import into the United States. If there's no US owner or buyer at the point of entry, the importer of record becomes the US agent representing the foreign exporter, confirmed by a signed statement of consent. This designation determines who FDA holds accountable if a shipment tests violative for adulteration or fails to meet any other requirement.
What the importer owns end to end
- FSVP hazard analysis and supplier verification — for each foreign honey supplier, explicitly addressing economically motivated adulteration alongside standard chemical and biological hazards
- Origin verification — supporting documentation for the declared country of origin, given honey's documented transshipment risk
- Prior Notice — filed and confirmed before the shipment arrives, with facility, product code, and origin details matched to the entry
- Recordkeeping — FSVP and sourcing records maintained for at least two years, producible on FDA request
- Label accuracy — verifying the statement of identity reflects whether the product is pure, blended, or flavored, with no undeclared sweeteners
Adulteration liability sits with the importer, not just the supplier
If a shipment tests violative for undeclared added sweeteners, FDA's response — refusal of entry, and potentially Detention Without Physical Examination on future shipments — attaches to the importing firm's record, not only the foreign supplier's. An importer who didn't independently verify a supplier's honey and relied solely on a vague compliance assurance is still the party accountable for that gap. Robust supplier verification isn't optional risk management here — see our FSVP requirements for honey guide for what that verification should include.
Recordkeeping in practice
FSVP records — hazard analyses, supplier evaluations, testing results, corrective actions — must be retained for at least two years and produced within a reasonable time of an FDA request. For honey specifically, this should include documentation supporting the declared country of origin, not just food-safety testing records, given the overlap between adulteration risk and origin fraud.
Frequently asked
Who is legally the honey importer of record?
The US owner or buyer at the time of import, or the US agent representing the foreign supplier if there's no US owner or buyer, confirmed by signed consent.
Is the importer liable if a supplier's honey turns out to be adulterated?
Yes — the importer of record is accountable for FSVP compliance including supplier authenticity verification, regardless of whether they were aware of the adulteration.